CPRW, which in 1998 celebrated its 70th anniversary,
is Wales' foremost voluntary charitable organisation specialising
in all issues relating to the conservation and enhancement of
the countryside, its environment and rural communities. In a single
phrase, CPRW's concern is for the living landscape.

1.2 CPRW's renewable energy policy

CPRW's democratically produced policy on renewable
energy accepts the need to reduce dependence on polluting and
fossil fuel power generation, coupled with improved conservation
measures and restraint in use, always provided that the benefits
outweigh or do not unnecessarily involve other adverse environmental
impacts.

1.3 CPRW's policy on wind energy installations

Since 1991 CPRW has refined this position in
the light of a concentrated wave of planning applications for
wind power stations which it considers individually and cumulatively
to have created unacceptable visual and other impacts on the Welsh
landscape. CPRW believes that projects have been unduly forced
on to the windiest and often most visible and beautiful sites
in upland and coastal areas by the competitive bidding element
of NFFO subsidy system which provides a guaranteed market for
successful tenderers. In 1995 it produced a definitive policy
on renewable energy installations (ref 1) with a specific sub-section
relating to wind energy. This provides the basis for a presumption
against large wind power stations in the open countryside and
sets out a series of circumstances in which small installations
might be acceptable.

1.4 CPRW's experience in relation to wind
energy proposals

In the process CPRW has gained considerable
experience in analysing the impact of proposals for what it considers
to be wind power stations (rather than the euphemistic "windfarms"
preferred by developers). It has evaluated many applicants' Environmental
Statements, and contributed to the statutory planning process
and policy formation at all levels. It retains a permanent consultant
on the subject; has played a leading role within the UK voluntary
sector on the issue; has developed the concept of forming professionally
represented coalitions to combine the evidence of like-minded
objectors at Public Inquiries; and has established a positive
working relationship on the subject with the Countryside Council
for Wales, the government's statutory adviser.

1.5 Scope of this Evidence

Because of its experience above, CPRW wishes
to concentrate its evidence on wind power.

2. EFFECTSOFTHE GOVERNMENT'SRENEWABLEENERGYPOLICYFORWINDPOWER

2.1 The policy background

In response to the EU target, the UK has adopted
its own target for 10 per cent of electricity consumption in 2010
to be met by all forms of renewable energy. A longer-term aim
of 20 per cent by 2025 is also in existence. The Department of
Trade and Industry has indicated that wind power will continue
to be the major component of the 10 per cent target and that by
2010 it might contribute about 6 per cent of electricity consumption,
with roughly half of that coming from land-based installations
and half from offshore installations (despite the fact that no
commercial offshore installations have yet been constructed).
We understand that these individual components do not constitute
formal targets, although recent indications are that the offshore
proportion might be slightly higher and on a strongly rising curve
by 2010. It is even possible that it could then eclipse, if not
entirely replace, land-based deployment in the progress to the
longer term 2025 objective.

2.2 The response of the wind energy industry

In its 1996 Policy Statement (ref 2) the British
Wind Energy Association had anticipated that wind power would
supply 4 per cent of consumption by 2010, and declared that "a
long term target of 10 per cent of the UK's electricity demand
being met from the wind by 2025 is perfectly feasible". However,
in more recent evidence to the House of Commons Trade and Industry
Committee (ref 3), 1998, the BWEA has increased its 2010 forecast
to 6 per cent, while repeating the former CEGB's view that an
intermittent supply "from non-firm sources" could increase
to 20 per cent "without changes being necessary to the grid
operating system". In 1998 the pressure group Greenpeace
and the power generator Border Wind published a manifesto (ref
4) claiming that offshore wind alone could produce 10 per cent
of UK electricity by 2010 and 30 per cent or even 40 per cent
by 2030, while arguing for a specific offshore incentive to enable
it to become economically competitive. We understand this is now
imminent, and will augment the replacement for the NFFO/SRO subsidy
system, without which the development of wind power and other
renewables would have been impossible.

2.3 The effect on the landscape to date

Between 1991 and 1998 about 750 wind turbines
were built in the UK (Table 1) of which approximately half were
in Wales (Table 2), progressively increasing in installed capacity
and size from 300kW (41.5m=136ft) to 600kW (60m=196ft). Most have
been erected in coastal and upland areas, notably Anglesey and
mid-Wales (where Montgomeryshire has the two largest wind power
stations then built in Europe). In April 1997 CPRW compiled a
populist colour brochure entitled Pla'r Twrbinau Gwynt: Ple
ar ran y Tirlun (Wind Turbine Blight: A Plea for the Landscape)
(ref 5) which concluded that the adverse visual and other impacts
arising from wind power station policy were outweighing the benefits
of stimulating a renewable source of energy. In May 1997 CPRW
united with CPRE and APRS (its sister organisations in England
and Scotland, the Ramblers' Association and the Council for National
Parks to produce a joint statement Wind Energy and the Landscape
(ref 6) calling on the newly elected government to "green"
the NFFO subsidies; to widen the menu of renewable technologies;
to strengthen protection for vulnerable landscapes; and to make
energy conservation an increased priority.

2.4 The implications of the 2010 target

2.4.1 Data from the DTI's Energy Technical
Support Unit (ETSU) shows that, due to the intermittency of suitable
medium-strength winds, the 318MW wind generating capacity functioning
during the year ending June 1998 operated at 26.7 per cent of
its nominal installed capacity (IC), producing 745,000,000 kWh
(745,000 MWh or 0.745 TWh)* (Table 3). This is 0.25 per cent of
the estimated 300TWh present annual consumption in the UK and
represents an average output of 85MW. Allowing for minor additional
output from the 8MW installed capacity of more recently constructed
turbines, present wind power generation is thus still well below
0.3 per cent of consumption, and therefore an increase in land-based
capacity greater than 10-fold would be needed to reach the indicated
3 per cent of 2010 levels.

2.4.2 On present trends this huge increase
would come from progressively higher capacity machines of 1.5MW
(c95m=312ft) and more, but due to their increased size and extended
threshold of visual intrusion (Appendix 1) their impact would
not be correspondingly diminished, and would be considerably intensified
at closer range. Moreover, the Countryside Commission (ref 7)
has indicated that the recent average annual 2.4 per cent rise
in consumption is likely to be maintained. If this was even 2
per cent per annum, annual electricity consumption in 2010 would
be about 373TWh. The balance still required to reach the 3 per
cent "target" of 11TWh/pa would therefore be 10.25TWh/pa.
This would require an actual output capability of 1,170MW*. On
the equally generous assumption that capacity factors for land-based
turbines might reach an overall average of 30 per cent this would
in turn require an installed capacity of 3,900MW**. This would
involve 2,600 1.5MW turbines or their equivalents at other capacities.

* 10,250,000MW / 8,760=1,170MW (there being 8,760
hours in a year)

** 1,170MW / 30%=3,900MW.

2.4.3 CPRW has found that such 95m=312ft
turbines could be visually intrusive at a 12km radius and readily
discernible at 22km (Appendix 1). Qualitative and cumulative impact
would be significantly exacerbated due to both turbine size and
numbers deployed and we recommend a radius of visual impact analysis
of 30km, compared with 20km for the current typical 55m turbines.
We are also concerned that the technical and conceptual basis
for assessing visual impact through environmental impact assessment
is inadequate, especially in respect of cumulative or incremental
impact, as set out in our response to ETSU's on-going research
study on the Cumulative Effects of Wind Turbines (ref 8).

2.4.4 In addition, the whole of the putative
3 per cent contribution from offshore turbines would be required,
and is likely to require some 1,800 or more 2MW turbines* (or
equivalent combination). Advances in technology may allow deployment
in non-sensitive areas and at non-intrusive distances from the
coast (more than 10km and preferably 15km) but this is still uncertain,
as is the nature of the consent and support regime, both of which
could make or mar the acceptability of the technology.

2.4.5 The 2010 target is an interim point
in a longer term strategy which requires a further doubling of
renewable capacity. The role of wind power is uncertain but offshore
deployment is by then likely to predominate. How environmentally
acceptable and economically attractive this may be is uncertain,
as is the weighting of adverse impacts in the policy decisions
which yet have to be made.

3. IMPLICATIONSFOR WALES

3.1 The 3 per cent objective

The 357 turbines already installed produce about
2.4 per cent of Wales' relatively small energy needs, thus effectively
almost meeting the general land-based objective already, although
it is likely that wind power may be expected to produce a disproportionately
large share of the 2010 target in Wales. Whether, by how much,
and with what balance between land-based and offshore is undetermined,
and at a recent Countryside Council for Wales Seminar (ref 9)
it was accepted by all sides that this was a practical and political
question to be addressed by the National Assembly.

3.2 Beyond 3 per cent

It has been CPRW's view since 1995 (supported
by other NGOs in England and Scotland) that the majority of existing
sites have unacceptable visual (and in some cases other) impacts.
Further substantial land-based turbine development geared to meeting
an appropriate larger share of the 2010 target would jeopardise
the integrity of extensive areas of high quality landscapes and
their enjoyment by the publicespecially in or around nationally
designated areas, or in the substantial portions of Wales ostensibly
protected by local designations such as Special Landscape Areas,
and Heritage Coasts. CPRW has argued to Planning Authorities,
at the Cemaes B Public Inquiry (ref 10), and in various submissions
notably that to the House of Commons Trade and Industry Committee
(ref 11) that this represents a most unfortunate major induced
conflict between policies for renewable energy and protection
of the countryside (for reasons set out above) and requires urgent
reconciliation at the highest level. In the meantime, the precautionary
principle should be applied to ensure that there is a presumption
in favour of landscape conservation rather than resource exploitation.

3.3 Policy issues

We can understand why the wind power industry,
which had relatively little opposition in the early years of turbine
development, is now bemoaning its lack of progress and has identified
the planning system as the greatest obstacle to achieving its
desired proportion of the renewable energy target (ref 3). Local
Planning Authorities have responded to the progressive disillusionment
of electorates in or near "windfarm" areasespecially
where cumulative impact and ever larger turbines have become issuesand
have begun to withhold consent for a growing proportion of applications.
Similarly, Appeals or Call-ins have been increasingly dismissed
at Public Inquiries. We regard the recent dismissal at Public
Inquiry of National Wind Power's appeal against refusal of consent
for the Barningham High Moor wind power station in County
Durham (refs 12 and 13)as having major implications for
the future deployment of wind power policy in Wales and the whole
of the UK. The appellants, who manifestly share this view, have
appealed to the High Court. The Inspector concluded that the installationconsiderably
larger than any built in Englandwould have "caused
demonstrable harm to the appearance of the landscape" and
that "its contribution of energy needs would be insignificant
and unreliable, and the pollution savings would be correspondingly
small, and uncertain". While we accept that some local benefits
exist, we would also argue that the average intermittant 85MW
produced erratically from disparate installations throughout the
UK is also insignificant and potentially unreliable in terms of
both the national demand and the distributional and regulatory
needs of the National Grid. We conclude, therefore, that the operation
of land-based wind power policy has produced successive tranches
of proposals which individually and collectively run contrary
to the Government's test that they should be both "economically
attractive and environmentally acceptable".

3.4 Conclusion

Implementation of the anticipated land-based
wind energy proportion of the general renewables target could
thus in our view only be achieved at an unacceptable cost to the
landscapes of Wales and those facets of the rural economy, such
as tourism and some aspects of the housing market, which derive
their viability from the unimpaired high quality of the landscape.
CPRW would argue that this would not only be a betrayal of the
post-war planning and landscape conservation system but would
be counter-productive to the wider national interest to pursue
these targets in the present manner. We would urge that a decisive
policy change is required to address the underlying issue and
we would in that sense regard the targets as unrealistic and unsustainable.
It is therefore unsurprising to us, that despite the damage done
to the landscape in the early years of the NFFO system, further
planning consents have been so bitterly fought and so rarely granted
in the light of the incremental impact of wind power station development.

4. SUMMARY

4.1 Response to the Committee's Questions

The first question goes to the heart of the
problem we have recognised:

(a) How realistic is the Commission's target
of 12 per cent of primary energy from renewables in the EU by
2010?

(b) How realistic is a 5 per cent target
of electricity from renewables in the EU by 2005?

(c) How likely are Member States, particularly
the UK, to achieve these targets?

We do not consider that the targets referred
to are "realistic" as far as land-based wind power is
concerned for the simple reason that we consider this aspect of
the policy itself to be unsustainable. It cannot take practical
effect without incurring unacceptable and progressive consequences.
As the Countryside Commission observed (ref 7) "there is
often an obvious contradiction between the requirement to secure
electricity at the cheapest price and the need to respect valued
landscapes" . . . concluding that "we do not feel it
makes sense to tackle one environmental problem by creating another".
"Tackle", not "solve", we note. The targets,
whether specific or implied, for land-based wind can only be achieved
at the expense of colossal and in our view unjustified damage
to the landscapes of Wales, and other parts of the UK. We do not
consider this to be an acceptable, sustainable or realistic way
to develop renewable energy. The image of land-based wind power
as a "clean green" renewable source is tarnished by
its propensity for visual intrusion at considerable distances
in high quality landscapes; localised noise intrusion; disruption
of local amenity and public enjoyment of the countryside; and
potential danger to horse riders on nearby bridleways and other
legal routes. These problems represent a subtle form of pollution
which in our view has been inadequately weighed in the balancing
exercise necessary to evaluate the benefits and role of a potentially
major renewable power source.

4.2 Current technologies available to meet
these targets and likely future developments

CPRW recognises that there are potential drawbacks
to probably all forms of renewable energy, but believes that land-based
wind power has been promoted as unduly benign and cost-effective,
and this has been to the detriment of other, potentially rival,
technologies. We note, for instance, the late but welcome inclusion
of wave-power in the SRO-3 announcement of February 1999 and look
forward to its development with interest.

4.3 Environmental effects of renewable energy
sources, and other benefits

We regard the effects of past and proposed wind
power development on the Welsh landscape and environment as profoundly
negative and destructive, and consider that there is rarely, if
ever, any net benefit.

Note: "Capacity" indicates the installed requirement
in megawatts (MW) to generate the contract (1MW=1,000 kilowatts).
Latest turbines range between 600kW and 1.5MW and generate up
to 30 per cent of capacity on a yearly average. A 12MW contract
could thus consist of 20 x 600kW turbines (typically 60m high)
or 8 x 1.5MW (up to 95m high). Contracts require subsequent planning
permission in which individual and cumulative visual impact is
the major factor: 60m turbines can be visually significant within
a 15km radius (20km forecast for 95m turbines).

Note: "Capacity" indicates the installed requirement
in megawatts (MW) to generate the contract (1MW = 1,000 kilowatts).
Latest turbines range between 600kW and 1.5MW and generate up
to 30 per cent of capacity on a yearly average. A 12MW contract
could thus consist of 20 x 600kW turbines (typically 60m high)
or 8 x 1.5MW (up to 95m high). Contracts require subsequent planning
permission in which individual and cumulative visual impact is
the major factor: 60m turbines can be visually significant within
a 15km radius (20km forecast for 95m turbines).

Note: 12-monthly rolling averages have been used in order
to accommodate seasonal variations. IC=Installed Capacity. Theoretical
maximum=IC x 8,760 (total hours in a year). CF=Capacity Factor=IC
as % of theoretical maximum. Where IC is not constant for the
relevant 12-monthly period an average figure has been used.

In September 1996 an attempt was made by Mr Gareth Thomas,
the Planning Officer of Montgomeryshire (arguably the local authority
with the greatest experience of dealing with wind power station
proposals) to define the potential visual impact of wind turbines
by descriptors which could be assessed in the field, and which,
with repeated observation, should produce a degree of observer
consistency. The approach assumes good normal visibility, and
is intended only to be a general guide, especially at the margins
of each band, recognising the importance of local conditions,
viewing direction, turbine angle and the scale and nature of the
landscape context. The Matrix incorporates the following nine
bands of visual impact ranging from "dominant" to "negligible",
identified as "A" to "I" in the Table below.

2. THEREVISED
THOMAS MATRIX

The Thomas Matrix was originally determined in respect of
the 25 and 31 metre hub machines at Cemaes and Llandinam (overall
height 41.5-45.5 metres respectively: significantly less than
that of turbines subsequently constructed throughout the UK).
Mr Thomas concluded from this that "15 kilometres is considered
to be the appropriate radius distance for study", although
many Zone of Visual Influence (ZVI) maps in Environmental Assessments
have employed a much smaller radius (even for much larger turbines).
Several hundred field observations have since been carried out
in the visual hinterlands of constructed wind power stations throughout
Britain by Geoffrey Sinclair of Environment Information Services
to test the Thomas Matrix and the relevant ZVI threshold. Initially
this exercise was confined to the two installations in Montgomeryshire
where the Thomas Matrix was developed, and then extended to others
using similar-sized machines. This established broad agreement
with Mr Thomas' descriptions of visual impact, but found that
his original distance bands were rather conservative. Minor amendments
were made to his distances, as shown by the results in the second
column of the Table below headed the "Revised Thomas Matrix".

3. THE SINCLAIR-THOMAS
MATRIX

The Thomas approach was extended to viewpoints around other
wind power stations which used larger turbines in order to establish
the extent to which distances for each visibility band (and thus
the appropriate ZVI radius) needed to be extended in relation
to the increase in turbine size. In practice, the larger turbines
used in most installations constructed since the 41-45 metre "1st
generation" have tended to cluster around 52-55 metres, and
the results for these are shown in the first column of what may
now be called the "Sinclair-Thomas Matrix". Provisional
results from the largest turbines subsequently built (the four
750kW 70 metre machines at Great Eppleton, Houghton-le-Spring,
County Durham) have also been used to construct a further tentative
set of distances. A projected series has been added to extrapolate
the sequence in relation to the latest proposals for the 1.5MW
95 metre turbines at Mynydd Hiraethog, North Wales.

THE "THOMAS" AND "SINCLAIR-THOMAS" MATRICES
to estimate the potential visual impact of different sizes of
wind turbines

6. Wind Energy and the Landscape: a Joint Statement by APRS,
CPRW, CNP, CPRE and the Ramblers' AssociationMay 1997;
accompanying CPRE Press Release 35/97 "Groups unite in calling
for new direction for wind power policy", and letter to the
President of the Board of Trade dated 15 May 1997

7. Call for a Change of Wind Direction: Response by the
Countryside Commission to the Government's consultation on the
Fifth Round of the NFFO, October 1997

8. Submission by CPRW to ETSU Research Study The Cumulative
Effects of Wind Turbines (CEWT) February 1999

9. Wind Turbines in the Welsh LandscapeLooking
for the Way Forward: Seminar organised by the Countryside
Council for Wales, 17 February 1999 (proceedings in course of
preparation, March 1999)

10. Public Inquiry into the extension of the Cemaes wind power
station (Cemaes B) Montgomeryshire, Proofs of Geoffrey Sinclair
(CPRW/GS/023) and Merfyn Williams (CPRW/MW/025) July 1998

11. The formulation and operation of policy on wind power
and its interaction with the planning system: Evidence to the
House of Commons Trade and Industry Committee inquiry on Aspects
of Energy PolicyCPRW, February 1998

12. Appeal and Application by National Wind Power Limited
(Barningham High Moor) ref APP/W1335/A/97/285005, Government Office
for the North East, November 1998